Copra treated as an oil-seed under the earlier sales tax definition, with later amendment used to confirm scope.

Copra (dry coconut) was treated as falling within the pre-amendment expression "oil-seeds" in section 14(vi) of the Central Sales Tax Act, 1956. The later amendment by Act 61 of 1972, which expressly included coconut/copra, was used as an aid to construction to clarify the scope of the earlier ambiguous wording. On that basis, sales of copra were stated to be taxable at 3 per cent under section 6(3) of the Bihar Sales Tax Act, 1959, in accordance with the pre-amendment understanding of the term.

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Issues: Whether copra, i.e. dry coconut, was an oil-seed within the meaning of section 14(vi) of the Central Sales Tax Act, 1956, and consequently taxable at 3 per cent under section 6(3) of the Bihar Sales Tax Act, 1959.

Analysis: The pre-amendment definition of oil-seeds in section 14(vi) of the Central Sales Tax Act, 1956 was considered in the light of the later amendment by Act 61 of 1972, which expressly included coconut/copra and thereby removed doubts. The earlier provision was treated as capable of covering dry coconut, and the later amendment was used as a relevant aid to understanding the scope of the earlier ambiguous wording. The reasoning adopted the view that copra fell within the expression oil-seeds under the unamended law.

Conclusion: Copra is an oil-seed within the meaning of section 14(vi) of the Central Sales Tax Act, 1956, and its sales are taxable at 3 per cent only under section 6(3) of the Bihar Sales Tax Act, 1959, in favour of the assessee and against the revenue.

Ratio Decidendi: Where the earlier statutory definition is ambiguous, a later amendment may be used as an aid to construction to ascertain the meaning of the earlier provision, and copra was held to fall within the pre-amendment expression oil-seeds.

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